ATA Letter to DOT Secretary Peters on JFK Congestion Solutions

November 14, 2007

The Honorable Mary E. Peters Secretary

U.S. Department of Transportation

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Dear Secretary Peters:

While we fully appreciate the difficult position that the Department faces to identify solutions to combat delays at JFK airport, we strongly urge you to focus on solutions other than instituting unreasonable caps on U.S. airlines at JFK or implementing congestion pricing. Either of these “solutions” are fraught with negative and unintended consequences. Quite simply – these “solutions” will raise airfares, undermine sacrifices already made by U.S. workers, and do little to relieve congestion in the long term.

We believe there are steps that can be taken immediately that may meet your intended objective without imposing the economic harm that will most assuredly follow if either the path of forced unrealistic reduction or congestion pricing is taken. Specifically, we urge you to endorse the time tested market approach followed in the rest of the world under the Worldwide Schedule Guidelines. This approach is a fair and transparent way to control congestion and also ensure that slots are used efficiently by allowing the marketplace to work.

In addition, we support the immediate appointment of a senior-level appointee or “czar” to direct resources to ensure timely implementation of possible solutions. By all accounts, the appointment of a Florida czar in the spring of 2005 proved to be the difference between success and failure in reducing Ft. Lauderdale airspace congestion through a systemic, expeditious process. As pointed out in the November 6 edition of the Wall Street Journal – the FAA’s math does not make sense. How can New York's La Guardia Airport with two runways handle 81 operations – and New York's John F. Kennedy International Airport with four runways, handle only 80 flights per hour? By the FAA’s reckoning, two additional runways translates into one less operation an hour. Something is amiss and it is our hope that an individual with laser focus on the problem can work with all stakeholders to find alternative solutions.

Other capacity improvements that should be pursued include the following:

• Accelerate Implementation of the New York/New Jersey Airspace Redesign
• Integrate and Prioritize NYARC Working Group One “Capacity Enhancements” and the FAA’s “New York Short-Term Initiative Tasks (as of 10/18/07)
• Initiate Dialogue on Air Traffic Controller Staffing
• Continue Efforts to Access Restricted Military Airspace
• Analyze Impact of High-Performance Noncommercial Operations in New York Congestion

Clearly this is a complex problem and one where the “silver bullet” solution of congestion pricing would ultimately simply damage the U.S. economy and the New York economy in particular. We believe that the solutions we have identified can meet the objective without causing economic harm. We look forward to continuing the dialogue with you.

                                 Sincerely,